INTERNATIONAL UNION, UNITED AUTOMOBILE, AEROSPACE & AGRICULTURAL IMPLEMENT WORKERS OF AMERICA – UAW

DENNIS WILLIAMS, President GARY CASTEEL, Secretary-Treasurer

VICE PRESIDENTS: CINDY ESTRADA • JIMMY SETTLES • NORWOOD JEWELL

IN REPLY REFER TO

November 10, 2015

1757 N STREET, N.W.

WASHINGTON, D.C. 20036

TELEPHONE: (202) 828-8500

FAX (202) 293-3457

Administrator McCarthy

Environmental Protection Agency

1200 Pennsylvania Avenue, NW

Washington, DC 20460 

Dear Administrator McCarthy: 

I want to commend you on your ongoing commitment to working with a diverse set of stakeholders to reduce carbon 

emissions. The UAW supports the Administration’s Climate Action Plan for reducing emissions of greenhouse gases, 

building clean energy infrastructure, increasing energy efficiency in our homes and workplaces, and creating new jobs in 

advanced and green technology industries. There is no scientific debate on the connection between fossil fuel 

consumption, rising carbon dioxide levels in the earth’s atmosphere, and climate change. Climate change is real, and if 

we ignore it, it would be to our own peril. It is clear that the COP21 climate talks in Paris will be important for developing a 

strong international framework to reduce emissions and comprehensively address climate change.

Today, I am writing to express concerns about important climate and job-creating policy: the federal Renewable Fuel 

Standard (RFS) rulemaking slated for completion on November 30th. Specifically I want to express our strong opposition 

to a proposed new waiver related to the “distribution” of renewable fuels. It could have serious unintended consequences 

for the Renewable Fuel Standards (RFS) program and has the potential of sending manufacturing and construction jobs 

overseas. Oil companies control distribution and have little incentive to accept biofuels. As you know, the fossil fuels 

industry has opposed RFS since its inception and has made their ongoing opposition perfectly clear. This waiver could 

dramatically undermine the demand for renewable fuels and dry up investment for new plants. This, in turn, could weaken 

demand for farming equipment built by tens of thousands of our members. 

Our members manufacture combines, tractors, and products needed by our emerging biofuel industry. Well over 10,000 

of these jobs are held by UAW workers at John Deere manufacturing facilities in Midwestern states. These workers have 

obtained good paying jobs that enable them to provide for their families and help build a stronger local economy. 

However, by implementing this proposed rule, high-skilled and specialized agricultural manufacturing jobs will be put at 

risk, thereby limiting the future growth of our manufacturing sector. Workers in states like Iowa and Illinois may be forced 

to retire or relocate to try to find new jobs, many of which may be lower wage. As our economy continues to recover from 

the Great Recession, we must not put in place policies that weaken our manufacturing base and the middle class.

Our manufacturing sector is viable and strong, particularly in the biofuels and renewable fuels industry. A significant 

reduction in renewable volume obligations under this proposed rule could destabilize the renewable fuel industry and send 

the wrong message to investors. As an ardent proponent of the Administration’s light-duty fuel efficiency standards, we at 

the UAW support growth in the next generation biofuels. Continuing to build our biofuels industry will keep America 

globally competitive, create even more jobs, improve the environment, and boost economic demand. I know with your 

leadership we can find the right balance for the RFS. 

We respectfully request that the EPA to not grant a new distribution waiver and put forward targets that are consistent with 

the 2007 law. This waiver would impose significant burdens and losses on rural American workers and the economies of 

their communities. Thank you for considering our views on this important matter.

Sincerely, 

Dennis D. Williams, President

International Union, UAW